Conflict Minerals Evolution: CFSI Now Provides the Missing Link

We aren’t intentionally on a kick about evolution (see our earlier article about faith versus proof in supplier data), but we couldn’t pass up this opportunity to pun it up with the “missing link” reference.

You may be aware that the EICC’s Conflict-Free Sourcing Initiative (CFSI) launched a newly designed website (  What is not widely known is the little gem in the navigation bar named “rcoi data”.  The unassuming lower case font belies the valuable information therein.

We previously pointed out that there has not been a way to link CFSP-audited smelters/refiners with their associated countries of origin in order to disclose that information in Conflict Minerals Reports (CMRs).   This has been a gap going way back – some of us remember when the EICC maintained an aggregated list of countries of origin, but without a way to associate them with smelters/refiners.  The closest that most companies were able to come was either by relying on Question #2 of the EICC-GeSI Conflict Minerals Reporting Template (whether 3TG originates from the Covered Countries), or undertaking their own efforts to contact identified smelters to identify their countries of origin.

CFSI is now providing a solution – that little “rcoi data” tab.  The CFSI collects country of origin for all CFSP-compliant smelters/refiners and shares that RCOI data with its members in a summarized format by smelter.   The RCOI reports issued by CFSI to its members include:

  • A complete list of all compliant smelters/refiners and category of their sources
  • Categories include
    • R/S: smelter which processes solely recycle/scrap
    • L1, L2, L3: smelters which process ore based raw material from Level 1, Level 2 or Level 3 as defined in the CFSP protocol; Level 3 being the “adjoining countries”
    • DRC: smelter which process ore based raw materials from the DRC specifically

“Being able to provide this information to our members is the result of over five years of intense work by industry and collaboration with many stakeholders. This is a huge milestone for the CFSI and we continue to work to attract more smelters to be CFSP-compliant,” said Julie Schindall, Director of Communications & Stakeholder Engagement at the EICC.

There are some things to bear in mind.  First, you do have to join the CFSI as a member.  Second, the RCOI data is still confidential and is disclosed to members after the Agreement on the Exchange of Confidential Information (AECI) has been executed.  This means that commercial IT solutions are not likely to gain access to the information for purposes of using it for their customers.  As a matter of fact, this is addressed on their membership page Benefits of CFSI membership, such as RCOI data, may not be provided by member associations to their own constituents.

In all seriousness, this is a very big development.  Maybe our characterization of this as the Missing Link is still too subtle – maybe Sasquatch is better.

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